ML16117A152

NRC Integrated Inspection Report 05000528/2016001, 05000529/2016001, and 05000530/2016001

ML16117A152
Person / Time
Site:	Palo Verde
Issue date:	04/25/2016
From:	Charley Peabody NRC/RGN-IV/DRP/RPB-D
To:	Edington R Arizona Public Service Co
Josey J
References
IR 2016001
Download: ML16117A152 (37)

See also: IR 05000528/2016001

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION IV

1600 E. LAMAR BLVD.

ARLINGTON, TX 76011-4511

April 25, 2016

Randall K. Edington

Executive Vice President, Nuclear/CNO

Mail Station 7602

Arizona Public Service Company

P.O. Box 52034

Phoenix, AZ 85072-2034

SUBJECT:

PALO VERDE NUCLEAR GENERATING STATION - NRC INTEGRATED

INSPECTION REPORT 05000528/2016001, 05000529/2016001, AND

05000530/2016001

Dear Mr. Edington:

On March 31, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection

at your Palo Verde Nuclear Generating Station Units 1, 2, and 3. On April 6, 2016, the NRC

inspectors discussed the results of this inspection with R. Bement, M. Lacal, and other members

of your staff. Inspectors documented the results of this inspection in the enclosed inspection

report.

NRC inspectors documented two findings of very low safety significance (Green) in this report.

Two of these findings involved violations of NRC requirements.

Further, inspectors documented a licensee-identified violation which was determined to be of

very low safety significance in this report. The NRC is treating this violation as non-cited

violation (NCV) consistent with Section 2.3.2.a of the NRC Enforcement Policy.

If you contest the violations or significance of the NCVs, you should provide a response within

30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear

Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with

copies to the Regional Administrator, Region IV; the Director, Office of Enforcement, U.S.

Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector

at the e Palo Verde Nuclear Generating Station.

If you disagree with the cross-cutting aspect assignment in this report, you should provide a

response within 30 days of the date of this inspection report, with the basis for your

disagreement, to the Regional Administrator, Region IV; and the NRC resident inspector at the

e Palo Verde Nuclear Generating Station.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public

Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your

response (if any) will be available electronically for public inspection in the NRCs Public

R. Edington

- 2 -

Document Room or from the Publicly Available Records (PARS) component of the NRC's

Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible

from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic

Reading Room).

Sincerely,

/RA/

Jeffrey E. Josey, Acting Chief

Project Branch D

Division of Reactor Projects

Docket Nos. 50-528, 50-529, 50-530

License Nos. NPF-41, NPF-51, NPF-74

Enclosure:

Inspection Report 05000528/2016001,

05000529/2016001, 05000530/2016001

w/ Attachment: Supplemental Information

cc w/ encl: Electronic Distribution

ML16117A152

SUNSI Review

By: JEJ

ADAMS

Yes No

Non-Sensitive

Sensitive

Publicly Available

Non-Publicly Available

Keyword:

NRC-002

OFFICE

DRP/SRI

DRP/RI

DRP/RI

C:DRS/EB1

C:DRS/EB2

C:DRS/OB

C:DRS/PS1

NAME

CPeabody

DReinert

DYou

TFarnholtz

GWerner

VGaddy

MHaire

SIGNATURE

/RA-E/

/RA-E/

/RA/

/RA/

/RA/

/RA/

JKirkland, for

/RA/

DATE

4/25/16

4/25/16

4/25/16

4/19/16

4/20/16

4/22/16

4/20/16

OFFICE

C:DRS/PS2

TL:IPAT

C:DRP/D

NAME

HGepford

THipschman

JJosey

SIGNATURE

/RA/

/RA/

/RA/

DATE

4/21/16

4/21/16

4/25/16

Letter to R. Edington from J. Josey dated April 25, 2016

SUBJECT:

PALO VERDE NUCLEAR GENERATING STATION - NRC INTEGRATED

INSPECTION REPORT 05000528/2016001, 05000529/2016001, AND

05000530/2016001

DISTRIBUTION:

Regional Administrator (Marc.Dapas@nrc.gov)

Deputy Regional Administrator (Kriss.Kennedy@nrc.gov)

DRP Director (Troy.Pruett@nrc.gov)

DRP Deputy Director (Ryan.Lantz@nrc.gov)

DRS Director (Anton.Vegel@nrc.gov)

DRS Deputy Director (Jeff.Clark@nrc.gov)

Senior Resident Inspector (Charles.Peabody@nrc.gov)

Resident Inspector (David.You@nrc.gov)

Resident Inspector (Dustin.Reinert@nrc.gov)

PV Administrative Assistant (Yvonne.Dubay@nrc.gov)

Acting Branch Chief, DRP/D (Jeffrey.Sowa@nrc.gov)

Senior Project Engineer, DRP (Vacant)

Project Engineer, DRP/D (Jim.Melfi@nrc.gov)

Public Affairs Officer (Victor.Dricks@nrc.gov)

Project Manager (Margaret.Watford@nrc.gov)

Team Leader, DRS/IPAT (Thomas.Hipschman@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

ACES (R4Enforcement.Resource@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov)

Technical Support Assistant (Loretta.Williams@nrc.gov)

Congressional Affairs Officer (Jenny.Weil@nrc.gov)

RIV Congressional Affairs Officer (Angel.Moreno@nrc.gov)

RIV/ETA: OEDO (Jeremy.Bowen@nrc.gov)

RIV RSLO (Bill.Maier@nrc.gov)

ACES (R4Enforcement.Resource@nrc.gov)

- 1 -

Enclosure

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket:

05000528, 05000529, 05000530

License:

NPF-41, NPF-51, NPF-74

Report:

05000528/2016001, 05000529/2016001, 05000530/2016001

Licensee:

Arizona Public Service Company

Facility:

Palo Verde Nuclear Generating Station

Location:

5801 South Wintersburg Road

Tonopah, AZ 85354

Dates:

January 1 through March 31, 2016

Inspectors: C. Peabody, Senior Resident Inspector

D. Reinert, PhD, Resident Inspector

D. You, Resident Inspector

L. Carson II, Senior Health Physicist

N. Greene, PhD, Health Physicist

Approved

By:

Jeffrey E. Josey

Acting Chief, Project Branch D

Division of Reactor Projects

- 2 -

SUMMARY

IR 05000528, 529, 530/2016001; 01/01/20106 - 03/31/2016; PALO VERDE NUCLEAR

GENERATING STATION; Occupational Dose Assessment and Follow-up of Events and Notices

of Enforcement Discretion.

The inspection activities described in this report were performed between January 1 and

March 31, 2016, by the resident inspectors at Palo Verde Nuclear Generating Station and

inspectors from the NRCs Region IV office and other NRC offices. Two findings of very low

safety significance (Green) are documented in this report. Two of these findings involve

violations of NRC requirements. The significance of inspection findings is indicated by their

color (Green, White, Yellow, or Red), which is determined using Inspection Manual

Chapter 0609, Significance Determination Process. Their cross-cutting aspects are

determined using Inspection Manual Chapter 0310, Aspects within the Cross-Cutting Areas.

Violations of NRC requirements are dispositioned in accordance with the NRC Enforcement

Policy. The NRCs program for overseeing the safe operation of commercial nuclear power

reactors is described in NUREG-1649, Reactor Oversight Process.

Cornerstone: Mitigating Systems

Green. The inspectors documented a self-revealing non-cited violation of Technical

Specification 3.7.2 Condition A for exceeding the allowed outage time of seven days.

Specifically Unit 3s MSIV-181 actuator B was found to be inoperable from May 1, 2015 until

August 15, 2015 when a design change installed a new swivel type fitting on an air-line

without taking into account vibrational forces, as required by the stations procedure. This

eventually resulted in the fatigue failure of the fitting, depressurizing the actuator B to less

than 5000 psig. The licensee entered this condition in their corrective action program and

performed a Level 2 cause evaluation under Condition Report 15-02686.

The inspectors concluded that the failure to take into account excessive vibrational stresses

as required by procedure 81DP-0EE10, Design Change Process Step J.2.9.1, when

implementing the design change was a performance deficiency. The performance

deficiency was more than minor because it affected the equipment performance attribute of

the Mitigating Cornerstone to ensure the availability, reliability, and the capability of systems

that respond to initiating events to prevent undesirable consequences. Specifically the

failure to account for the vibrational stresses resulted in the fatigue failure of the air-line

fitting which depressurized one of two hydraulic accumulators thereby reducing the reliability

of the system to initiate a fast closure of MSIV-181 upon receipt of a Main Steam Isolation

Signal. The inspectors performed the initial significance determination using NRC Inspection

Manual 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, Issue Date:

06/19/12. The finding screened as Green since the MSIV remained capable of performing

its safety function with the alternate accumulator. The finding has a cross-cutting aspect in

the area of human performance associated with the avoid complacency component.

Specifically the licensee assumed there were no factors affecting the mechanical design

requirements beyond the performance requirements. As a result the licensee failed to

perform a thorough review of the mechanical conditions (such as vibrations) the air-line was

subjected. [H.12]

- 3 -

Cornerstone: Occupational Radiation Safety

Green. A self-revealing non-cited violation of 10 CFR 20.1701 was identified for the

licensees failure to implement adequate processes or engineering controls to control the

concentration of radioactive material in air and prevent internal dose to workers.

Specifically, on April 14, 2015, the licensee implemented inadequate engineering and

radiological controls to remove a pre-filter and Y-connector from a high efficiency particulate

air (HEPA) ventilation unit resulting in an airborne radioactivity condition and two intakes.

The licensee was alerted to this issue when two radiation protection technicians alarmed

PM12 portal monitors upon their exit from the radiologically controlled area. The licensee

took immediate corrective actions and instructed these technicians to report to dosimetry for

whole body counting and evaluation. The licensee entered this issue into their corrective

action program as Condition Report (CR) CR 16-01093.

The failure to implement adequate engineering and radiological controls during HEPA unit

maintenance in accordance with procedures and the radiological exposure permit

requirements was a performance deficiency. The performance deficiency was more than

minor because it was associated with the Occupational Radiation Safety attribute of

Program and Process and adversely affected the cornerstone objective to ensure the

adequate protection of the worker health and safety from exposure to radiation from

radioactive material during routine civilian nuclear reactor operation. This was evident by

two workers receiving unplanned intakes. Using IMC 0609, Appendix C, Occupational

Radiation Safety Significance Determination Process, issue date 8/19/2008, the finding was

determined to be of very low safety significance (Green) because it did not involve: (1) as

low as reasonably achievable (ALARA) planning and controls, (2) an overexposure, (3) a

substantial potential for an overexposure, or (4) an impaired ability to assess dose. The

inspectors concluded that the finding has a Conservative Bias cross-cutting aspect in the

Human Performance area because the licensee failed to use decision-making practices that

emphasized prudent choices over those that are simply allowable when they changed out

the HEPA pre-filter and Y-connector components [H.14]. (Section 2RS4)

Licensee-Identified Violations

A violations of very low safety significance that was identified by the licensee has been reviewed

by the inspectors. Corrective actions taken or planned by the licensee have been entered into

the licensees corrective action program. This violation and associated corrective action

tracking numbers are listed in Section 4OA7 of this report.

- 4 -

PLANT STATUS

Units 1, 2, and 3 operated at effective full power for the duration of the inspection period.

REPORT DETAILS

1R04 Equipment Alignment (71111.04)

.1

Partial Walkdown

a.

Inspection Scope

The inspectors performed partial system walk-downs of the following risk-significant

systems:

January 5, 2016, Unit 3 4160V vital electrical bus A

March 2, 2016, Unit 1 diesel generator B

March 15, 2016, Unit 1 and Unit 3 diesel generators fuel oil head vent tanks

March 24, 2016, Unit 2 diesel generator A fuel oil storage and transfer system

The inspectors reviewed the licensees procedures and system design information to

determine the correct lineup for the systems. They visually verified that critical portions

of the systems were correctly aligned for the existing plant configuration.

These activities constituted four partial system walk-down samples as defined in

Inspection Procedure 71111.04.

b.

Findings

No findings were identified.

.2

Complete Walkdown

a.

Inspection Scope

On March 29, 2016, the inspectors performed a complete system walk-down inspection

of the Unit 2 essential chilled water system. The inspectors reviewed the licensees

procedures and system design information to determine the correct essential chilled

water system lineup for the existing plant configuration. The inspectors also reviewed

outstanding work orders, open condition reports, temporary modifications, and other

open items tracked by the licensees operations and engineering departments. The

inspectors then visually verified that the system was correctly aligned for the existing

plant configuration.

This activity constituted one complete system walk-down sample, as defined in

Inspection Procedure 71111.04

- 5 -

b.

Findings

No findings were identified.

1R05 Fire Protection (71111.05)

.1

Quarterly Inspection

a.

Inspection Scope

The inspectors evaluated the licensees fire protection program for operational status

and material condition. The inspectors focused their inspection on five plant areas

important to safety:

January 11, 2016, Unit 2 control room area, fire zone 17

February 1, 2016, Unit 3 train A vital switchgear room, fire zone 5A

February 16, 2016, Unit 2 diesel generator B, fire zones 21B and 22B

February 18, 2016, Unit 3 diesel generator B, fire zone 21B

February 18, 2016, Unit 1 diesel generator A, fire zone 21A

For each area, the inspectors evaluated the fire plan against defined hazards and

defense-in-depth features in the licensees fire protection program. The inspectors

evaluated control of transient combustibles and ignition sources, fire detection and

suppression systems, manual firefighting equipment and capability, passive fire

protection features, and compensatory measures for degraded conditions.

These activities constituted five quarterly inspection samples, as defined in Inspection

Procedure 71111.05

b.

Findings

No findings were identified.

1R06 Flood Protection Measures (71111.06)

a.

Inspection Scope

On February 4, 2016, the inspectors completed an inspection of the stations ability to

mitigate flooding due to internal causes. After reviewing the licensees flooding analysis,

the inspectors chose one plant area containing risk-significant structures, systems, and

components that were susceptible to flooding:

Unit 2 essential pipe chase tunnel

The inspectors reviewed plant design features and licensee procedures for coping with

internal flooding. The inspectors walked down the selected areas to inspect the design

features, including the material condition of seals, drains, and flood barriers. The

- 6 -

inspectors evaluated whether operator actions credited for flood mitigation could be

successfully accomplished.

This activity constitutes completion of one flood protection measure as defined in

Inspection Procedure 71111.06

b.

Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

(71111.11)

.1

Review of Licensed Operator Requalification

a.

Inspection Scope

On January 27, 2016, the inspectors observed an evaluated simulator scenario

performed by an operating crew. The inspectors assessed the performance of the

operators and the evaluators critique of their performance.

This activity constitutes completion of one quarterly licensed operator requalification

program sample, as defined in Inspection Procedure 71111.11

b.

Findings

No findings were identified.

.2

Review of Licensed Operator Performance

a.

Inspection Scope

On January 19, 2016, the inspectors observed the performance of on-shift licensed

operators in the plants main control room. At the time of the observations, Unit 3 was in

a period of heightened activity due to conducting a 24-hour diesel generator B run

followed by a load rejection test and a hot start test.

In addition, the inspectors assessed the operators adherence to plant procedures,

including Conduct of Shift Operations procedure and other operations department

policies.

This activity constitutes completion of one quarterly licensed operator performance

sample, as defined in Inspection Procedure 71111.11

b.

Findings

No findings were identified.

- 7 -

1R12 Maintenance Effectiveness (71111.12)

a.

Inspection Scope

The inspectors reviewed two instances of degraded performance or condition of safety-

related structures, systems, and components (SSCs):

February 25, 2016, Unit 2 charging pump A, repetitive failures due to improper

finger plate installation

March 30, 2016, Unit 2 diesel generator A, sheared support bolt for the fuel oil

head tank

The inspectors reviewed the extent of condition of possible common cause SSC failures

and evaluated the adequacy of the licensees corrective actions. The inspectors

reviewed the licensees work practices to evaluate whether these may have played a

role in the degradation of the SSCs. The inspectors assessed the licensees

characterization of the degradation in accordance with 10 CFR 50.65 (the Maintenance

Rule), and verified that the licensee was appropriately tracking degraded performance

and conditions in accordance with the Maintenance Rule.

These activities constituted completion of two maintenance effectiveness samples, as

defined in Inspection Procedure 71111.12.

b.

Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)

a.

Inspection Scope

The inspectors reviewed four risk assessments performed by the licensee prior to

changes in plant configuration and the risk management actions taken by the licensee in

response to elevated risk:

February 8, 2016, Unit 1 weekly risk assessment

February 15-21, 2016, Unit 3 work week 1607 risk assessment

February 29, 2016, Unit 1 weekly risk assessment during train A super outage

March 30, 2016, Unit 2 diesel generator B during the super outage

The inspectors verified that these risk assessment were performed timely and in

accordance with the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant

procedures. The inspectors reviewed the accuracy and completeness of the licensees

risk assessments and verified that the licensee implemented appropriate risk

management actions based on the result of the assessments.

Additionally, on March 16, 2016, the inspectors observed portions of one emergent work

activity that had the potential to affect the functional capability of mitigating systems:

- 8 -

March 16, 2016, Unit 2 risk assessment revision due to discovery sheared bolt

on diesel generator A fuel oil head tank

The inspectors verified that the licensee appropriately developed and followed a work

plan for these activities. The inspectors verified that the licensee took precautions to

minimize the impact of the work activities on unaffected structures, systems, and

components (SSCs).

These activities constitute completion of five maintenance risk assessments and

emergent work control inspection samples, as defined in Inspection Procedure 71111.13.

b.

Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments (71111.15)

a.

Inspection Scope

The inspectors reviewed seven operability determinations that the licensee performed

for degraded or nonconforming structures, systems, or components (SSCs):

January 8, 2016, Unit 3 venturi fouling factor adjustment following the steam

generator #1 ultrasonic flow meter failure

February 1, 2016, Unit 2 diesel generator A for non-qualified spray pond piping

configuration

February 2, 2016, Unit 3 steam supply valve to auxiliary feedwater pump A

February 2, 2016, Unit 3 diesel generator A for leaking roof hatch

February 2, 2016, Unit 2 essential cooling water surge tank A automatic makeup

valve leaking by

February 17, 2016, Unit 1 spray pond B return piping wall thinning

March 2, 2016, Unit 2 auxiliary feedwater pump A trip/throttle valve for loose

mounting bolt

The inspectors reviewed the timeliness and technical adequacy of the licensees

evaluations. Where the licensee determined the degraded SSC to be operable, the

inspectors verified that the licensees compensatory measures were appropriate to

provide reasonable assurance of operability. The inspectors verified that the licensee

had considered the effect of other degraded conditions on the operability of the

degraded SSC.

These activities constitute completion of seven operability and functionality review

samples, as defined in Inspection Procedure 71111.15.

- 9 -

b.

Findings

No findings were identified.

1R18 Plant Modifications (71111.18)

.1

Temporary Modifications

a.

Inspection Scope

On March 3, 2016, the inspectors reviewed one temporary plant modification that

affected risk-significant structures, systems, and components (SSCs): Unit 1 temporary

spray pond piping configuration during diesel generator outage.

The inspectors verified that the licensee had installed this temporary modification in

accordance with technically adequate design documents. The inspectors verified that

this modification did not adversely impact the operability or availability of affected SSCs.

The inspectors reviewed design documentation and plant procedures affected by the

modification to verify the licensee maintained configuration control.

These activities constitute completion of one sample of temporary modifications, as

defined in Inspection Procedure 71111.18

b.

Findings

No findings were identified.

.2

Permanent Modifications

a.

Inspection Scope

One March 15, 2016, the inspectors reviewed one permanent plant modification that

affected risk-significant structures, systems, and components (SSCs): Unit 3 main

steam isolation valve 181 actuator B air supply line vibration dampener.

The inspectors reviewed the design and implementation of the modification. The

inspectors verified that work activities involved in implementing the modification did not

adversely impact operator actions that may be required in response to an emergency or

other unplanned event. The inspectors verified that post-modification testing was

adequate to establish the operability of the SSC as modified.

These activities constitute completion of one sample of permanent modifications, as

defined in Inspection Procedure 71111.18.

b.

Findings

No findings were identified.

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1R19 Post-Maintenance Testing (71111.19)

a.

Inspection Scope

The inspectors reviewed seven post-maintenance testing activities that affected risk-

significant structures, systems, or components (SSCs):

February 9, 2016, Unit 1 diesel generator A, air compressor B

February 11, 2016, station blackout generator #2 following rebuild of pre-lube

motor

March 1, 2016, Unit 1 essential chiller A, following replacement of temperature

controllers

March 5, 2016, Unit 1 diesel generator A, following maintenance outage

March 16, 2016, Unit 2 diesel generator A, following replacement of fuel oil head

tank bolts

March 19, 2016, Unit 1 charging pump B, following 12 month and 24 month

preventive maintenance activities

March 30, 2016, Unit 2 diesel generator B following super outage

The inspectors reviewed licensing- and design-basis documents for the SSCs and the

maintenance and post-maintenance test procedures. The inspectors observed the

performance of the post-maintenance tests to verify that the licensee performed the tests

in accordance with approved procedures, satisfied the established acceptance criteria,

and restored the operability of the affected SSCs.

These activities constitute completion of seven post-maintenance testing inspection

samples, as defined in Inspection Procedure 71111.19.

b.

Findings

No findings were identified.

1R22 Surveillance Testing (71111.22)

a.

Inspection Scope

The inspectors observed five risk-significant surveillance tests and reviewed test results

to verify that these tests adequately demonstrated that the structures, systems, and

components (SSCs) were capable of performing their safety functions:

In-service tests:

January 25, 2016, Unit 3 auxiliary feedwater train B inservice test

- 11 -

Other surveillance tests:

January 18, 2016, Unit 3 diesel generator B surveillance test

February 17, 2016, Unit 2 diesel generator B surveillance test

March 14, 2016, Unit 3 control element assembly operability check

March 17, 2015, Unit 1 diesel generator B surveillance test

The inspectors verified that these tests met technical specification requirements, that the

licensee performed the tests in accordance with their procedures, and that the results of

the test satisfied appropriate acceptance criteria. The inspectors verified that the

licensee restored the operability of the affected SSCs following testing.

These activities constitute completion of five surveillance testing inspection samples, as

defined in Inspection Procedure 71111.22

b.

Findings

No findings were identified.

Cornerstone: Emergency Preparedness

1EP6 Drill Evaluation (71114.06)

.1

Emergency Preparedness Drill Observation

a.

Inspection Scope

On March 1, 2016, the inspectors observed an emergency preparedness drill to verify

the adequacy and capability of the licensees assessment of drill performance. The

inspectors reviewed the drill scenario, observed the drill from the TSC, and attended the

post-drill critique. The inspectors verified that the licensees emergency classifications,

off-site notifications, and protective action recommendations were appropriate and

timely. The inspectors verified that any emergency preparedness weaknesses were

appropriately identified by the licensee in the post-drill critique and entered into the

corrective action program for resolution.

These activities constitute completion of one emergency preparedness drill observation

sample, as defined in Inspection Procedure 71114.06.

b.

Findings

No findings were identified.

.2

Training Evolution Observation

a.

Inspection Scope

On January 27, 2016, the inspectors observed simulator-based licensed operator

requalification training that included implementation of the licensees emergency plan.

The inspectors verified that the licensees emergency classifications, off-site

- 12 -

notifications, and protective action recommendations were appropriate and timely. The

inspectors verified that any emergency preparedness weaknesses were appropriately

identified by the evaluators and entered into the corrective action program for resolution.

These activities constitute completion of one training observation sample, as defined in

Inspection Procedure 71114.06

b.

Findings

No findings were identified.

2.

RADIATION SAFETY

Cornerstones: Public Radiation Safety and Occupational Radiation Safety

2RS2 Occupational ALARA Planning and Controls (71124.02)

a.

Inspection Scope

The inspectors assessed licensee performance with respect to maintaining individual

and collective radiation exposures as low as is reasonably achievable (ALARA). The

inspectors performed this portion of the attachment as a post-outage review. During the

inspection the inspectors interviewed licensee personnel, reviewed licensee documents,

and evaluated licensee performance in the following areas:

Radiological work planning, including work activities of exposure significance,

and radiological work planning ALARA evaluations, initial and revised exposure

estimates, and exposure mitigation requirements. The inspectors also verified

that the licensees planning identified appropriate dose reduction techniques,

reviewed any inconsistencies between intended and actual work activity doses,

and determined if post-job (work activity) reviews were conducted to identify

lessons learned.

Verification of dose estimates and exposure tracking systems including the basis

for exposure estimates, and measures to track, trend, and if necessary reduce

occupational doses for ongoing work activities. The inspectors evaluated the

licensees method for adjusting exposure estimates and reviewed the licensees

evaluations of inconsistent or incongruent results from the licensees intended

radiological outcomes.

Problem identification and resolution for ALARA planning and controls. The

inspectors reviewed audits, self-assessments, work-in-progress and post-job

ALARA reviews, and corrective action program documents to verify problems

were being identified and properly addressed for resolution.

These activities constitute completion of two of the five required samples of occupational

ALARA planning and controls as defined in Inspection Procedure 71124.02.

b.

Findings

No findings were identified.

- 13 -

2RS4 Occupational Dose Assessment (71124.04)

a.

Inspection Scope

The inspectors evaluated the accuracy and operability of the licensees personnel

monitoring equipment, verified the accuracy and effectiveness of the licensees methods

for determining total effective dose equivalent, and verified that the licensee was

appropriately monitoring occupational dose. The inspectors interviewed licensee

personnel, walked down various portions of the plant, and reviewed licensee

performance in the following areas:

External dosimetry accreditation, storage, issue, use, and processing of active

and passive dosimeters

The technical competency and adequacy of the licensees internal dosimetry

program

Adequacy of the dosimetry program for special dosimetry situations such as

declared pregnant workers, multiple dosimetry placement, and neutron dose

assessment

Audits, self-assessments, and corrective action documents related to dose

assessment since the last inspection

These activities constituted five occupational dose assessment samples, as defined in

Inspection Procedure 71124.04.

b.

Findings

Introduction. The inspectors reviewed a self-revealing non-cited violation (NCV)

of 10 CFR 20.1701 of very low safety significance (Green) associated with the licensees

failure to implement adequate processes or other engineering controls, to the extent

practical, to control the concentration of radioactive material in air. Specifically, the

licensee failed to mist and bag a High Efficiency Particulate Air (HEPA) ventilation unit

component, use lapel samplers, complete breathing zone air samples, and use an

appropriate radiation exposure permit (REP) task. These failures led to an airborne

radioactivity condition that resulted in two workers having intakes resulting in internal

exposures of 15.2 millirem and 9.7 millirem, respectively.

Description. On April 14, 2015, during Refueling Outage 18 for Unit 3, two radiation

protection technicians (RPTs) (one senior and one junior) were assigned to change out

the pre-filter for a HEPA stationed on the 100-foot level of the steam generator platform.

Although the assigned RPTs had performed this job in the past, the filter change out

activity was normally performed by decontamination technicians with RPT oversight.

However, the RPTs were confident that they could complete the assigned task without

an issue, and the radiation protection (RP) supervisor approved.

The tasks included removing the filter, misting it, bagging it, and disposing of the filter.

However, the same radiological and engineering controls were not implemented for the

radioactive Y-connector that was also removed from the HEPA. The two RPTs signed

- 14 -

onto REP 3-3306, Task 1, which was categorized as low radiological risk. This task

allowed the technicians to complete vacuum change outs, transport vacuums, and other

tasks authorized by an RP Leader. The task did not specify HEPA maintenance. The

HEPA maintenance was specified on Task 31 of this REP, which was categorized as a

medium radiological risk job. Task 1 of REP 3-3306 stated that continuous RP coverage

was required for change outs and identified numerous hold points for specific RP Leader

approval.

One of those hold points stated that No vacuum bag change out greater than

100 mrem/hr at 30 cm on this task. It also stated that DECON/DIRECT HANDLING OF

ITEMS > or = 1,000 mrem/hr on contact requires RP Leader authorization. The filter

removed from the HEPA was surveyed and measured 1,500 millirem per hour on

contact and 160 millirem per hour at 30 cm. Thus, based on the RP hold points for

Task 1, this job should have stopped for further RP Leader approval. Based on the

identified dose rates on the filter, additional radiological and engineering controls should

have been administered to the tasks and increased risk. The inspectors also noted that

this task did allow high radiation area entry.

The licensee confirmed in their post-evaluation that lapel samplers should have been

worn by the RPTs. In addition, breathing zone air samples should have been taken to

evaluate the airborne radioactivity in the work area once the pre-filter and aluminum

Y-connector were removed from the HEPA unit. These measures would have monitored

the airborne radioactivity concentration that the RPTs were breathing. Thus, the RPTs

failed to gain additional RP Leader approval for handling the high dose components

(filter and Y-connector), failed to wear lapel air samplers, failed to conduct breathing

zone air samples, and failed to sign in on the appropriate REP task.

Although the RPTs were incorrectly signed onto Task 1 of the REP, the inspectors

reviewed the TEDE-ALARA evaluation for Task 31 of REP 2-3306 provided by the

licensee. The evaluation estimated that the use of respirators would increase the

external dose to workers performing duties under this activity by nearly 14 percent.

Thus, respirators were not required for the task. However, the licensee stated that

internal dose for this evolution was estimated by the evaluation to be 3 millirem, on

average. The NRC inspectors determined that the estimated internal dose (3 millirem)

was not specifically documented in the evaluation reviewed. However, the RPTs

assigned to perform the HEPA pre-filter change out were not signed onto Task 31

of REP 3-3306, but rather on Task 1 of this REP, which did not have a TEDE-ALARA

evaluation. The inspectors determined the 15.2 millirem CEDE (for the senior RPT)

and 9.7 millirem CEDE (for the junior RPT) intakes were unintended or unplanned dose.

The licensee was alerted to this issue when the two RPTs exited the radiologically

controlled area and alarmed the PM12 portal monitors. The licensee took immediate

corrective actions and instructed these individuals to report to dosimetry for monitoring,

re-surveyed the areas, and conducted an extensive evaluation of the issue. The

licensee entered this issue into their corrective action program as CR16-01093.

Analysis. The failure to implement adequate engineering and radiological controls

during HEPA maintenance in accordance with procedures and the radiological exposure

permit requirements was a performance deficiency. The performance deficiency was

more than minor because it was associated with the Occupational Radiation Safety

attribute of Program and Process and adversely affected the cornerstone objective to

- 15 -

ensure the adequate protection of the worker health and safety from exposure to

radiation from radioactive material during routine civilian nuclear reactor operation. This

was evident by two workers receiving unplanned intakes. Using IMC 0609, Appendix C,

Occupational Radiation Safety Significance Determination Process, issue date

8/19/2008, the finding was determined to be of very low safety significance (Green)

because it did not involve: (1) as low as reasonably achievable (ALARA) planning and

controls, (2) an overexposure, (3) a substantial potential for an overexposure, or (4) an

impaired ability to assess dose. The inspectors concluded that the finding has a

Conservative Bias cross-cutting aspect in the Human Performance area because the

licensee failed to use decision-making practices that emphasized prudent choices over

those that are simply allowable when they changed out the HEPA pre-filter and

Y-connector components [H.14].

Enforcement. Title 10 CFR 20.1701 states, in part, that the licensee shall use, to the

extent practical, process or other engineering controls to control the concentration of

radioactive material in air. Contrary to the above, on April 14, 2015, the licensee failed

to use, to the extent practical, process or other engineering controls to control the

concentration of radioactive material in air. Specifically, the licensee failed to use the

correct REP task and follow the requirements of the assigned REP, mist and bag the

Y-connector of the HEPA, wear lapel samplers, and collect/analyze breathing zone air

samples. Consequently, the failure to use adequate radiological and engineering

controls resulted in two unplanned intakes. The licensee took immediate corrective

actions and instructed the workers to report to dosimetry for monitoring, re-surveyed the

areas, and conducted extensive evaluation of the issue. Due to these actions and no

potential for overexposures, this issue was not identified as an immediate safety

concern. Because the violation is of very low safety significance (Green) and the

licensee has entered the issue into their corrective action program as CR-1601093, this

violation is being treated as a NCV, consistent with Section 2.3.2 of the NRC

Enforcement Policy: NCV 05000530/2016001-01, Failure to use adequate engineering

and radiological controls resulting in two unplanned intakes.

4.

OTHER ACTIVITIES

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency

Preparedness, Public Radiation Safety, Occupational Radiation Safety, and

Security

4OA1 Performance Indicator Verification (71151)

.1

Unplanned Scrams per 7000 Critical Hours (IE01)

a.

Inspection Scope

The inspectors reviewed licensee event reports (LERs) for the period of January, 1,

2015, through December 31, 2015 to determine the number of scrams that occurred.

The inspectors compared the number of scrams reported in these LERs to the number

reported for the performance indicator. The inspectors used definitions and guidance

contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment

Performance Indicator Guideline, Revision 7, to determine the accuracy of the data

reported.

- 16 -

These activities constituted verification of the unplanned scrams per 7000 critical hours

performance indicator for Units 1, 2, and 3 respectively, as defined in Inspection

Procedure 71151.

b.

Findings

No findings were identified.

.2

Unplanned Power Changes per 7000 Critical Hours (IE03)

a.

Inspection Scope

The inspectors reviewed operating logs, corrective action program records, and monthly

operating reports for the period of January, 1, 2015, through December 31, 2015, to

determine the number of unplanned power changes that occurred. The inspectors

compared the number of unplanned power changes documented to the number reported

for the performance indicator. The inspectors used definitions and guidance contained

in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance

Indicator Guideline, Revision 7, to determine the accuracy of the data reported.

These activities constituted verification of the unplanned power outages per 7000 critical

hours performance indicator for Units 1, 2, and 3 respectively, as defined in Inspection

Procedure 71151.

b.

Findings

No findings were identified.

.3

Unplanned Scrams with Complications (IE04)

a.

Inspection Scope

The inspectors reviewed the licensees basis for including or excluding in this

performance indicator each scram that occurred January, 1, 2015, through

December 31, 2015. The inspectors used definitions and guidance contained in Nuclear

Energy Institute Document 99-02, Regulatory Assessment Performance Indicator

Guideline, Revision 7, to determine the accuracy of the data reported.

These activities constituted verification of the unplanned scrams with complications

performance indicator for Units 1, 2, and 3 respectively, as defined in Inspection

Procedure 71151.

b.

Findings

No findings were identified.

.4

Safety System Functional Failures (MS05)

a.

Inspection Scope

For the period of January, 1, 2015, through December 31, 2015, the inspectors reviewed

licensee event reports (LERs), maintenance rule evaluations, and other records that

- 17 -

could indicate whether safety system functional failures had occurred. The inspectors

used definitions and guidance contained in Nuclear Energy Institute Document 99-02,

Regulatory Assessment Performance Indicator Guideline, Revision 7, and

NUREG-1022, Event Reporting Guidelines: 10 CFR 50.72 and 50.73, Revision 3, to

determine the accuracy of the data reported.

These activities constituted verification of the safety system functional failures

performance indicator for Units 1, 2, and 3 respectively, as defined in Inspection

Procedure 71151.

b.

Findings

No findings were identified.

4OA2 Problem Identification and Resolution (71152)

.1

Routine Review

a. Inspection Scope

Throughout the inspection period, the inspectors performed daily reviews of items

entered into the licensees corrective action program and periodically attended the

licensees condition report screening meetings. The inspectors verified that licensee

personnel were identifying problems at an appropriate threshold and entering these

problems into the corrective action program for resolution. The inspectors verified that

the licensee developed and implemented corrective actions commensurate with the

significance of the problems identified. The inspectors also reviewed the licensees

problem identification and resolution activities during the performance of the other

inspection activities documented in this report.

b. Findings

No findings were identified.

.2

Annual Follow-up of Selected Issues

a. Inspection Scope

The inspectors selected two issues for an in-depth follow-up:

On February 10, 2016, Unit 2 Class 1E inverter failure apparent cause evaluation

report

March 17, 2016, Unit 2 pressurizer level control exceed the high level limit resulting

from control valve maintenance

The inspectors assessed the licensees problem identification threshold, cause analyses,

extent of condition reviews and compensatory actions. The inspectors verified that the

licensee appropriately prioritized the planned corrective actions and that these actions

were adequate to correct the condition.

- 18 -

These activities constitute completion of two annual follow-up samples as defined in

Inspection Procedure 71152.

b. Findings

No findings were identified.

4OA3 Follow-up of Events and Notices of Enforcement Discretion (71153)

These activities constitute completion of one event follow-up sample, as defined in Inspection

Procedure 71153.

.1

(Closed) Licensee Event Report 05000530/2015-004-01, Condition Prohibited by

Technical Specification 3.0.4 and 3.7.2 Due to an Inoperable Main Steam Isolation Valve

a. Event Summary

On August 13, 2015, at approximately 9:06 p.m., the Unit 3 main steam isolation valve

181 (MSIV-181) actuator B was declared inoperable and Technical Specification (TS)

Limiting Condition for Operation (LCO) 3.7.2, Condition A, was entered due to a failed

fitting on the air supply line. To correct the condition the failed fitting was replaced and

an additional pipe support was installed on the air-line. Following retests, the MSIV-181

actuator B was restored to operable status and LCO 3.7.2, Condition A, was exited on

August 15, 2015 at approximately 6:30 p.m. On May 19, 2015, a similar air-line fitting

failure had occurred on the same component.

The licensees investigation of this condition following the second failure determined the

MSIV-181 actuator B air-line configuration was modified in the spring 2015 refueling

outage and was inoperable from Mode 4 entry on May 1, 2015, at 2:58 a.m., following

the outage because the air-line tubing was not adequately supported following the

design change. The licensee also found that a lack of a local visual inspection of actual

plant conditions resulted in the excessive vibration remaining unnoticed prior to the

component failure. The excessive vibration ultimately caused the fitting on the air

supply line to fail resulting in the inoperability of the MSIV-181 actuator B. The

inspectors reviewed the licensee event report and dispositioned this issue as a self-

revealing non-cited violation. This licensee event report is closed.

b. Findings

Introduction. The inspectors reviewed a Green self-revealing non-cited violation of

Technical Specification 3.7.2 Condition A for exceeding the allowed outage time of

seven days. Specifically, Unit 3s MSIV-181 actuator B was found to be inoperable from

May 1, 2015, until August 15, 2015, when a design change installed a new swivel type

fitting on an air-line without taking into account vibrational forces. This eventually

caused a fatigue failure of the fitting, depressurizing the accumulator B to below

5000 psig.

Description. During the April 2015, Unit 3 refueling outage, the licensee implemented a

design change which was to install a new type of swivel fitting on the air line to MSIV-

181 actuator B. The purpose of this change was to facilitate online maintenance by

replacing the rigid type fittings with swivel type fittings. As part of the design change

process, the station procedure, 81DP-0EE10 Design Change Process, requires that

- 19 -

special mechanical requirements such as vibrations be identified and addressed. The

design change documentation noted no impact to any special mechanical requirements.

Unit 3 completed their refueling outage and entered Mode 1 on May 3, 2015.

On May 19, 2015, at 4:23 a.m., the Unit 3 control room received alarms when the MSIV-

181 accumulator B pressure unexpectedly dropped below 5000 psig. The operators

entered Technical Specification 3.7.2 Condition A for an inoperable actuator train on one

MSIV. Field operators found that the new swivel type fitting had completely sheared

resulting in an air leak from accumulator B. Accumulator A was unaffected. The failed

fitting was repaired and restored to an operable status later the same day. Additionally

the licensee initiated a level 2 cause evaluation for the component failure.

During a visual walkdown of the affected air supply line, engineers noted excessive

vibrations. A walkdown other air supply lines did not exhibit such vibration. A vibrational

analysis was performed and determined that the tubing would be susceptible to fatigue

failure. Engineering analysis concluded the fitting would last for approximately 300 days

under this cyclical load. However a second fitting failure occurred on August 13, 2015,

to the same fitting. The senior reactor operator declared MSIV-181 B accumulator

inoperable and entered Technical Specification Action Statements 3.7.2 Condition A for

an inoperable actuator train. In addition to replacing the fitting a second time, the

licensee added supports to the airline to dampen vibrations. The Unit 3 senior reactor

operator declared MSIV-181 operable on August 15, 2015.

The licensees cause evaluation found that no physical walkdown was performed to

determine special mechanical requirements as required in step J.2.9.1 of procedure

81DP-0EE10, Design Change Process. A past operability evaluation concluded that

MSIV-181 accumulator B was inoperable from May 1, 2015, until August 15, 2015.

Additionally Technical Specification Limiting Condition for Operability 3.0.4 was not met

due to entry into Mode 4 with an LCO not met and the conditional requirements of LCO 3.0.4 also not met.

Analysis. The failure to take into account excessive vibrational stresses as required by

procedure 81DP-0EE10, Design Change Process step J.2.9.1, when implementing the

design change to an air-line fitting was a performance deficiency. The performance

deficiency was more-than-minor and therefore a finding because it affected the

equipment performance attribute of the Mitigating Systems Cornerstone to ensure the

availability, reliability, and capability of systems that respond to initiating events to

prevent undesirable consequences. Specifically the failure to account for the vibrational

stresses resulted in the fatigue failure of the air-line fitting depressurizing one of two

hydraulic accumulators thereby reducing the reliability of the system to initiate a fast

closure of MSIV-181 upon receipt of a Main Steam Isolation Signal. The inspectors

performed the initial significance determination using NRC Inspection Manual 0609,

Appendix A, Exhibit 2, Mitigating Systems Screening Questions, Issue Date: 06/19/12.

The finding screened as Green since the MSIV remained capable of performing its

safety function with the alternate accumulator. The finding has a cross-cutting aspect in

the area of human performance associated with the avoid complacency component.

Specifically the licensee assumed there were no factors affecting the mechanical design

requirements beyond the performance requirements. As a result the licensee failed to

perform a thorough review of the mechanical conditions (such as vibrations) the airline

was subjected. [H.12]

- 20 -

Enforcement. Technical Specification 3.7.2 requires that all four Main Steam Isolation

Valves (MSIVs) and their associated actuator trains shall be operable. Condition A

allows a single accumulator to be inoperable for a period of 7 days. Contrary to the

above a past operability determination found that Unit 3s MSIV-181 actuator B was

inoperable from May 1, 2015, to August 15, 2015. The inoperability of the actuator B

was the result of the licensee failing to account for vibrational stresses when

implementing a design change of an air-line fitting. The vibrational stresses eventually

caused the fatigue failure of the fitting resulting in the depressurization of the hydraulic

accumulator B rendering it inoperable. The licensees immediate corrective actions were

to install additional supports to dampen the vibrations of the air line and conducted an

inspection for excessive vibrations on the other pneumatic lines to ensure the problem

does not exist on any other plant components. Because this finding is of very low safety

significance and has been entered into the licensees corrective action program as

Condition Report 15-02686, this violation is being treated as a non-cited violation in

accordance with Section 2.3.2 of the Enforcement Policy: NCV 05000530/2016001-02,

Fatigue failure of a pneumatic fitting due to excessive vibrations.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On January 22, 2016, the inspectors presented the radiation safety inspection results to

Mr. G. Andrews, Director of Nuclear Regulatory Affairs, and other members of the licensee staff.

The licensee acknowledged the issues presented. The licensee confirmed that any proprietary

information reviewed by the inspectors had been returned or destroyed.

On April 6, 2016, the inspectors presented the inspection results to R. Bement, M. Lacal, and

other members of the licensee staff. The licensee acknowledged the issues presented. The

licensee confirmed that any proprietary information reviewed by the inspectors had been

returned or destroyed.

4OA7 Licensee-Identified Violations

The following violation of very low safety significance (Green) was identified by the licensee and

is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for

being dispositioned as a non-cited violation.

Technical Specification 5.4.1, Procedures, requires that procedures be established,

implemented, and maintained covering the applicable procedures in Regulatory Guide

1.33. Regulatory Guide 1.33, Appendix A, Section 9 requires, in part, that maintenance

that can affect the performance of safety-related equipment be properly preplanned and

performed in accordance with written procedures. Contrary to the above, prior to

October 1, 2015, licensee work management personnel failed to perform an activity

affecting quality in accordance with written procedures.

Specifically, the licensee did not conduct an adequate review of technical specification

LCO implications of a planned Unit 2 essential spray pond outage in accordance with

procedure 51DP-9OM08, Look Ahead Process. Work planners did not recognize that

the removal of two spray pond piping spool pieces was an activity required to restore

spray pond system operability and therefore did not establish a tracking mechanism to

ensure that the spool pieces were removed before the Unit 2 essential spray pond A was

- 21 -

declared operable. Consequently, the Unit 2 essential spray pond A would not have

been able to provide cooling to the essential cooling water heat exchanger following a

seismic event. The inspectors evaluated the significance of the issue under the

Significance Determination Process, as defined in Inspection Manual Chapter 0609.04,

Initial Characterization of Findings, and 0609 Appendix A, The Significance

Determination Process (SDP) for Findings at-Power, dated June 19, 2012. Inspectors

concluded the finding was of very low safety significance (Green) because all questions

in Exhibit 2 could be answered no. The licensee entered the issue into the corrective

action program as CR 15-08352. The licensee now plans and controls the removal and

re-installation of spray pond spool pieces using the stations temporary modification

process.

A1-1

Attachment 1

ATTACHMENT 1

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

R. Bement, Sr. Vice President of Nuclear Operations

M. Lacal, Sr. Vice President of Regulatory and Oversight

J. Cadogan, Vice President, Engineering

C. Kharrl, Plant General Manager for Operations

M. McLaughlin, Plant General Manager of Site Support

D. Vogt, Assistant Plant Manager Unit 2

D. Wilson, Shift Manager

H. Ridenour, Director Maintenance

G. Andrews, Director Regulatory Affairs

D. Wheeler, Director Performance Improvement

K. Graham, Director Plant Engineering

K. House, Director Design Engineering

M. McGhee, Department Leader, Nuclear Regulatory Affairs

J. Glass, Department Leader, Performance Improvement

M. Radspinner, Department Leader, System Engineering

R. Tremayne, Department Leader, Work Management

M. Hooshmand, Department Leader, Nuclear Assurance

G. Cameron, Section Leader, Nuclear Regulatory Affairs

H. Lesan, Section Leader, Performance Improvement

L. McKinney, Section Leader, Security

J. Rodriguez, Compliance Engineer

S. Dornseif, Compliance Engineer

C. Stephenson, Licensing Engineer

J. Bungard, Superintendent, Technical Support (Acting)

T. Dickinson, Unit 3 RMC Supervisor, Radiation Protection

D. Heckman, Senior Compliance Consultant, Regulatory Affairs

G. Jones, Supervisor, Radiation Protection

S. Lantz, Dosimetry Section Leader, Radiation Protection

C. Moeller, Director, Technical Support (Acting)

R. Routolo, Manager, Radiation Protection (Acting)

M. Wagner, Supervisor, ALARA and Radiation Protection

NRC Personnel

C. Peabody, Senior Resident Inspector

D. Reinert, Resident Inspector

D. You, Resident Inspector

L. Carson II, Senior Health Physicist

N. Greene, PhD. Health Physicist

A1-2

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000530/2015-004-01 LER Condition Prohibited by Technical Specifications 3.0.4 and 3.7.2

due to an inoperable main steam isolation valve

(Section 4OA3.1)05000530/2016001-01

NCV Failure to use adequate engineering and radiological controls

resulting in two unplanned intakes05000530/2016001-02

NCV Fatigue failure of pneumatic fitting due to excessive vibrations

LIST OF DOCUMENTS REVIEWED

Section 1R04: Equipment Alignment

Procedures

Number

Title

Revision

40OP-9PB01

4.16kV Class 1E Power (PB)

31

40OP-9DG02

Emergency Diesel Generator B

73

40OP-9DF01

Diesel Fuel Oil Storage and Transfer (DF)

42

40OP-9EC02

Essential Chilled Water Train B

29

40OP-9EC02

Essential Chilled Water Train A

30

Miscellaneous

Number

Title

Date

System Health Report - Essential Chilled Water

September 30, 2015

Section 1R05: Fire Protection

Procedures

Number

Title

Revision

40AO-9ZZ19

Control Room Fire

31

14OP-9FP02

CO2 Fire Protection (CARDOX)

9

18FT-9FP39

Functional Test of Appendix A Fire/HELB Doors

0

Condition Reports (CRs)

16-02078

A1-3

Miscellaneous

Number

Title

Revision/Date

Pre-Fire Strategies Manual

25

PVNGS Updated FSAR

18

Pre-Fire Strategies Manual

25

13-VTD-C285-

0005-1

Chemtron Low Pressure Carbon Dioxide Systems,

Operation & Maintenance Manual, [PUB # 11B]

85-FP-110

Engineering Evaluation Request

November 16, 2015

Section 1R06: Flood Protection Measures

Calculations

Number

Title

Revision

13-MC-ZY599

Essential Pipe Density Tunnel Flooding

Section 1R11: Licensed Operator Requalification Program and Licensed Operator

Performance

Procedures

Number

Title

Revision/Date

40DP-9OP02

Conduct of Shift Operations

68

SES-0-03-Q-09

Licensed Operator Continuing Training Simulator

Evaluation Scenario

December 22, 2015

Section 1R12: Maintenance Effectiveness

Condition Reports (CRs)

Miscellaneous

Number

Title

Revision/Date

CH-1203

Maintenance Rule (a)(1) Issue Tracking Form

6

System Health Report

Q4-2015

System Health Report - Diesel Generator

Q4-2015

Unit 2 Maintenance Rule SSC Unavailability Report

March 3, 2016

Palo Verde Maintenance Rule Manager Database

15-07224

16-01437

A1-4

Section 1R13: Maintenance Risk Assessments and Emergent Work Control

Procedures

Number

Title

Revision

40ST-9EC03

Essential Chilled Water and Ventilation Systems Inoperable

Actions Surveillance

20

70DP-0RA01

Shutdown Risk Assessments

50

Condition Reports (CRs)

Miscellaneous

Number

Title

Date

Schedulers Evaluation for PV Unit 1

February 7, 2016

Schedulers Evaluation for PV Unit 1

February 29, 2016

Schedulers Evaluation for PV Unit 2

March 16, 2016

Schedulers Evaluation for PV Unit 2

March 24, 2016

Section 1R15: Operability Determinations and Functionality Assessments

Procedures

Number

Title

Revision

40OP-9ZZ05

Power Operations

143

40DP-9OP26

Operations Condition Reporting Process and Operability

Determination/Functional Assessment

42

Condition Reports (CRs)

Miscellaneous

Number

Title

Revision/Date

4732426

Engineering Evaluation

January 6, 2016

M018-00322

Lube Oil Circulation Pump Motor Data

13-MC-ZZ-0217

Engineering Calculation

7

16-02709

16-04066

15-13087

16-00265

15-08352-002

15-08352

16-01578

06-02062

15-10486

15-10883

15-10418

16-00245

16-02578

16-01561

16-03246

A1-5

Miscellaneous

Number

Title

Revision/Date

4740953

Engineering Evaluation

4723071

Engineering Evaluation

4749946

Engineering Evaluation

Section 1R18: Plant Modifications

Procedures

Number

Title

Revision

81DP-0DC17

Temporary modification Control

36

Work Orders

Miscellaneous

Number

Title

Revision

4435636

Design Equivalent Change: Alternate Air Fitting for

MSIV/FWIV Air check Valve Connection to Manifold

3

Section 1R19: Post-Maintenance Testing

Procedures

Number

Title

Revision

40ST-9GT03

Station Blackout Generator 2 Monthly Test

6

40ST-9DG01

Diesel Generator A Test

45

73ST-9CH06

Charging Pumps - Inservice Test

26

40ST-9DG02

Diesel Generator B Test

49

Condition Reports (CRs)

Work Orders

4745046

16-04066

16-04136

16-04152

4743659

4592359

4754245

4754870

4580405

4603460

4486471

4542945

4542965

4732477

4479572

4725145

A1-6

Section 1R22: Surveillance Testing

Procedures

Number

Title

Revision

73ST-9SG08

Class 1E Diesel Generator Load Rejection, 24 Hour Rated

Load and Hot Start Test Train B

10

73ST-9AF03

Auxiliary Feedwater B - Inservice Test

27

40ST-9DG02

Diesel Generator B Test

49

40ST-9SF01

CEA operability check

35

Work Orders

4575857

4580516

4589871

Section 1EP6: Drill Evaluation

Procedures

Number

Title

Date

SES-0-03-Q-09

Licensed Operator Continuing Training Simulator

Evaluation Scenario

December 22, 2015

Section 2RS2: Occupational ALARA Planning and Controls

Procedures

Number

Title

Revision

74CH-9XC73

Tritium

05

75DP-0RP06

ALARA Committee

06

75DP-0RP08

Managing Radiological Risk

02

75RP-9RP02

Radiation Exposure Permits

29

75RP-9RP12

ALARA Reports

05

75RP-9RP28

Radioactive Process Filter Management

06

75TD-9RP02

ALARA Work Planning

08

75RP-9RP25

Temporary Shielding

14

75TD-9RP04

Operations Manual

06

Radiation Exposure Permits

Number

Title

Revision

1-3306

Primary Side Steam Generator Maintenance

01

3-3002

Reactor Destack and Restack

04

9-1021

LR Evaporator & BAC System Maintenance

03

A1-7

Radiation Exposure Permits

Number

Title

Revision

9-1105

Fuel Handling

01

1-3003

Reactor Vessel Head (RVH) O-Ring Maintenance and

Flange Inspection

03

2-3509

Contamination Control Outage Tasks

05

3-3306

Primary Side Steam Generator Maintenance

06

Palo Verde Condition Reports

1601058

1510580

1508339

1508336

1505025

1504942

1504939

1503936

1503147

1503090

1502333

1502221

1502040

1502034

Miscellaneous Documents

Number

Title

Date

Unit-3 3R18 Outage Report

June 18, 2015

ALARA 5 Year Plan 2015 - 2019

November 7, 2015

PCR 4677906

UFSAR Section 12 Per Dry Cask Special Tools

November 20, 2015

DMWO 4304156 ALARA Design Review HPSI Piping

December 9, 2013

Unit-2 2R19 Outage Report

December 22, 2015

Radiological Safety Trends

December 31, 2015

Audits, Self-Assessments, and Surveillances

Number

Title

Date

2014 Annual ALARA/Management Evaluation Report

June 29, 2015

A1-8

Section 2RS4: Occupational Dose Assessment

Procedures

Number

Title

Revision

75DP-0RP01

RP Program Overview

11

75DP-0RP06

Managing Radiological Risk

02

75RP-9ME21

TLD Issue, Exchange and Termination

13

75RP-9ME23

Exposure Evaluation for Lost, Damaged, or Suspect Dosimetry,

and Anticipated EPD Dose Rate Alarm

12

75RP-9ME24

Dosimetry Processing, Evaluation, and Documentation

05

75RP-9ME25

TLD Reader Calibration and Response Check

06

75RP-9RP02

Radiation Exposure Permits

29

75RP-9RP03

Bioassay Analysis

10

75RP-9RP05

Contamination Dose Evaluation

07

75RP-9RP16

Special Dosimetry

20

Audits, Self-Assessments, And Surveillances

Number

Title

Date

100536-0

NVLAP Onsite Assessment Summary

May 6, 2014

218-03732-

TSG/GRN

2013 Annual Radiation Protection Program Summary

Report

May 30, 2014

Palo Verde Condition Reports

1501820

1502248

1503644

1505076

1507237

1508308

1508385

1508590

1508823

1509662

1509732

1510410

1510844

1510977

1511554

1511845

1601093

Radiation Exposure Permits (REPs)

Number

Title

Revision

1-3003

Reactor Vessel Head (RVH) O-Ring Maintenance and Flange

Inspection

03

2-3509

Contamination Control Outage Tasks

05

3-3306

Primary Side Steam Generator Maintenance

06

A1-9

Miscellaneous Documents

Number

Title

Revision/Date

Dosimetry Program Quality Manual

16

Dosimetry Comparison Failures

2015

100536-0/F, G 2014 NVLAP Proficiency Testing Report

June 13, 2014

2-3306-31

TEDE/ALARA Evaluation

July 23, 2015

100536-0/H, I

2014 NVLAP Proficiency Testing Report

August 15, 2014

TLD Reader

No. 468119

TLD Reader Calibration and Response Check

September 24, 2015

100536-0

NVLAP Certificate of Accreditation to ISO/IEC

17025:2005

October 1, 2015

Waste Stream Report: Unit 1 Dry Active Waste

January 5, 2016

Waste Stream Report: Unit 2 Dry Active Waste

January 5, 2016

Waste Stream Report: Unit 3 Dry Active Waste

January 5, 2016

218-03946-

JER

Fourth Quarter 2015 ISFSI Area TLD Monitoring

Results

January 7, 2016

TLD Reader

No. 256069

TLD Reader Calibration and Response Check

January 15, 2016

Section 4OA1: Performance Indicator Verification

Miscellaneous Documents

Number

Title

Revision

NEI 99-02

Regulatory Assessment Performance Indicator Guideline

7

Section 4OA2: Problem Identification and Resolution

Condition Reports (CRs)

4654418

4639503

4650188

4650483

A2-1

Attachment 2

Attachment 2

The following items are requested for the

Occupational Radiation Safety Inspection

Integrated Report 2016-001

at

Palo Verde Nuclear Station

(January 19-22, 2016)

Inspection areas are listed in the attachments below.

Please provide the requested information on or before January 8, 2016

Please submit this information using the same lettering system as below. For example, all

contacts and phone numbers for Inspection Procedure 71124.01 should be in a file/folder titled

1- A, applicable organization charts in file/folder 1- B, etc.

If information is placed on ims.certrec.com, please ensure the inspection exit date entered is at

least 30 days later than the onsite inspection dates, so the inspectors will have access to the

information while writing the report.

In addition to the corrective action document lists provided for each inspection procedure listed

below, please provide updated lists of corrective action documents at the entrance meeting.

The dates for these lists should range from the end dates of the original lists to the day of the

entrance meeting.

If more than one inspection procedure is to be conducted and the information requests appear

to be redundant, there is no need to provide duplicate copies. Enter a note explaining in which

file the information can be found.

If you have any questions or comments, please contact Louis Carson at (817)200-1221,

Louis.Carson@nrc.gov or Natasha Greene at (817)200-1154, Natasha.Greene@nrc.gov

PAPERWORK REDUCTION ACT STATEMENT

This letter does not contain new or amended information collection requirements subject

to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information

collection requirements were approved by the Office of Management and Budget,

control number 3150-0011.

A2-2

2. Occupational ALARA Planning and Controls (71124.02)

Date of Last Inspection: April 17, 2015

A. List of contacts and telephone numbers for ALARA program personnel

B. Applicable organization charts

C. Copies of audits, self-assessments, and LERs, written since date of last inspection,

focusing on ALARA

D. Procedure index for ALARA Program

E. Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures may be requested by number after the inspector reviews

the procedure indexes.

1. ALARA Program

2. ALARA Committee

3. Radiation Work Permit Preparation

F. A summary list of corrective action documents (including corporate and sub-tiered

systems) written since date of last inspection, related to the ALARA program. In addition

to ALARA, the summary should also address Radiation Work Permit violations,

Electronic Dosimeter Alarms, and RWP Dose Estimates

NOTE: The lists should indicate the significance level of each issue and the search

criteria used. Please provide in document formats which are searchable so that the

inspector can perform word searches.

G. List of work activities greater than 1 rem, since date of last inspection

Include original dose estimate and actual dose.

H. Site dose totals and 3-year rolling averages for the past 3 years (based on dose of

record)

I. Outline of source term reduction strategy

J. If available, provide a copy of the ALARA outage report for the most recently completed

outages for each unit

K. Please provide your most recent Annual ALARA Report.

4. Occupational Dose Assessment (Inspection Procedure 71124.04)

Date of Last Inspection: April 17, 2015

A. List of contacts and telephone numbers for the following areas:

1. Dose Assessment personnel

B. Applicable organization charts

A2-3

C. Audits, self-assessments, vendor or NUPIC audits of contractor support, and LERs

written since date of last inspection, related to:

1. Occupational Dose Assessment

D. Procedure indexes for the following areas

1. Occupational Dose Assessment

E. Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures will be requested by number after the inspector reviews

the procedure indexes.

1. Radiation Protection Program

2. Radiation Protection Conduct of Operations

3. Personnel Dosimetry Program

4. Radiological Posting and Warning Devices

5. Air Sample Analysis

6. Performance of High Exposure Work

7. Declared Pregnant Worker

8. Bioassay Program

F. List of corrective action documents (including corporate and sub-tiered systems) written

since date of last inspection, associated with:

1. National Voluntary Laboratory Accreditation Program (NVLAP)

2. Dosimetry (TLD/OSL, etc.) problems

3. Electronic alarming dosimeters

4. Bioassays or internally deposited radionuclides or internal dose

5. Neutron dose

NOTE: The lists should indicate the significance level of each issue and the search

criteria used. Please provide in document formats which are searchable so that the

inspector can perform word searches.

G. List of positive whole body counts since date of last inspection, names redacted if

desired

H. Part 61 analyses/scaling factors

I. The most recent National Voluntary Laboratory Accreditation Program (NVLAP)

accreditation report or, if dosimetry is provided by a vendor, the vendors most recent

results

PAPERWORK REDUCTION ACT STATEMENT

This letter does not contain new or amended information collection requirements subject

to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information

collection requirements were approved by the Office of Management and Budget,

control number 3150-0011.